The appellant appealed his income tax assessments for the 2016 and 2017 taxation years, seeking relief on the basis that his former employer withheld but failed to remit income tax from his pay.
The Crown brought a motion to quash the appeal for lack of jurisdiction.
The Tax Court of Canada quashed the appeal, holding that the failure of an employer to remit withheld taxes is a collection problem under subsection 222(2) of the Income Tax Act, which falls within the exclusive jurisdiction of the Federal Court.